Massachusetts Clean Marina Guide

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M ASSAC HUSETTS CLEAN M ARIN A G UIDE

Strategies to Reduce Environmental Impacts

A C oastal Zone M anagement/ EO EA publication


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MassachusettsClean Marina Guide

Strategies to ReduceEnvironmental Impacts

Prepared by Epsilon Associates, Inc.for the Massachusetts Office ofCoastal Zone Management

April 2001


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Table of ContentsChapter One: Introduction

1.1 The Case for Clean Marinas............................................................1-1

1.2 The Guide and the Marina Assistance Program ................................1-2

1.3 Marina Regulations........................................................................1-41.4 Who Should Use this Guidebook ....................................................1-4

Marinas ................................................................................................1-4

Yacht Clubs ..........................................................................................1-4

Boatyards ..............................................................................................1-4

Municipalities........................................................................................1-5

Boaters..................................................................................................1-5

Do-It-Yourselfers ..................................................................................1-5

1.5 Guide Purpose and Organization ....................................................1-6

Chapter Two: The Coastal Environment and Pollution Impacts

2.1 The Massachusetts Coast................................................................2-1

Currents,Waves,and Tides ....................................................................2-2

Coastal Water Chemistry ........................................................................2-2

Coastal Habitats ....................................................................................2-3

2.2 Marina Activities and Potential Impacts to the Marine Environment........2-4

Hull Maintenance ..................................................................................2-4

Boat Cleaning ........................................................................................2-5

Gas and Oil from Engine Maintenance,Bilge Water, and Fueling ..............2-5

Boat Sewage ..........................................................................................2-6

Solid Waste............................................................................................2-6Fish Waste ............................................................................................2-7

2.3 Protecting the Massachusetts Marine Environment ..........................2-7

Chapter Three: Clean Marina Operations and Management

3.1 Staff Training ................................................................................3-1

3.2 Tools to Help Communicate Clean Boatingto Customers ..............3-2

Customer Contracts ..............................................................................3-2

Contractor Agreements ..........................................................................3-3

Signs ....................................................................................................3-3

Fact Sheets ............................................................................................3-4

Notices and Clean Boating Tips..............................................................3-4

Clean Boating Events ............................................................................3-4

Promoting the Marinas Good Work........................................................3-5

3.3 Financing Clean Business Practices ................................................3-5

New Services ........................................................................................3-5

Sell Environmentally-Preferable Products................................................3-6

Environmental Surcharge ......................................................................3-6

Itemized Environmental Charges ............................................................3-6

Massachusetts Clean Marina Guide Table of Contents


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Chapter Four: Activities and Environmental Practices

4.1 Hull Maintenance and Cleaning ......................................................4-3

4.2 Boat Cleaning ............................................................................4-11

4.3 Engine Maintenance ....................................................................4-15

4.4 Bilge Water Handling ..................................................................4-21

4.5 Fueling........................................................................................4-27

4.6 Spill Response ............................................................................4-334.7 Boat Sewage and Wastewater Management ....................................4-37

4.8 Shoreside Facilities and Pet Waste Management ..............................4-43

4.9 Solid Waste Management ............................................................4-47

4.10 Hazardous Materials and Hazardous Waste Management ................4-53

4.11 Fish Waste Management ..............................................................4-59

4.12 Stormwater Management..............................................................4-63

4.13 Boat Operations ..........................................................................4-69

Chapter Five: New and Expanding Marinas

5.1 Environmental Considerations........................................................5-25.2 Applicable Regulations ..................................................................5-3

5.3 Siting and Design Considerations....................................................5-5

Marina Flushing ....................................................................................5-5

Water Quality ........................................................................................5-6

Habitat..................................................................................................5-7

Shoreline Streambank Stabilization ........................................................5-8

5.4 More Information ..........................................................................5-9

Chapter Six: Major Regulatory Programs

6.1 Regulatory Overview ....................................................................6-1

6.2 Statutes and Regulations ................................................................6-6

1. Areas of Critical Environmental Concern ............................................6-7

2. Coastal Wetlands Restriction Act ........................................................6-7

3. Executive Order 149: Federal Emergency Management

Agency and Floodplain Use ................................................................6-8

4. Executive Order 181: Barrier Beaches ................................................6-8

5. Massachusetts Endangered Species Act ..............................................6-8

6. Federal Endangered Species Act..........................................................6-9

7. Underwater Archeological Resources ..................................................6-9

8. Massachusetts Historical Commission ..............................................6-109. Massachusetts Division of Marine Fisheries ......................................6-10

10. National Marine Fisheries Service....................................................6-11

11. Ocean Sanctuaries Act ....................................................................6-11

12. Designated Port Areas ....................................................................6-12

13. Municipal Harbor Plans..................................................................6-12

14. Massachusetts Environmental Policy Act ........................................6-13

15. Wetlands Protection Act..................................................................6-13

16. 401 Water Quality Certification ......................................................6-14



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17. Public Waterfront Act (Chapter 91) ................................................6-14

18. State Fire Marshall Massachusetts Fire Code................................6-15

19. Coastal Zone Management..............................................................6-15

20. Rivers and Harbors Act of 1899 (Section 10) ..................................6-16

21. Clean Water Act (Section 404) ........................................................6-16

22. Marine Protection, Research and Sanctuaries Act (Section 103) ........6-16

23. Massachusetts Programmatic General Permit ..................................6-1624. NPDES Stormwater Construction General Permit............................6-18

25. Order of Conditions ......................................................................6-18

26. Chapter 91 license ..........................................................................6-18

27. NPDES Storm Water Multi-Sector General Permit ..........................6-19

28. Marine Sanitation Devices ..............................................................6-19

29. No Discharge Areas ........................................................................6-20

30. Clean Vessel Act ............................................................................6-20

31. Resource Conservation and Recovery Act........................................6-21

32. Discharge of Oil Clean Water Act ................................................6-22

33. Organotin Antifoulant Paint Control Act..........................................6-22

34. Marine Plastic Pollution Research and Control Act ..........................6-23

35. Control of Volatile Organic Compounds Clean Air Act ................6-23

36. Boat Engine Emissions Massachusetts Clean Air Act ....................6-24

37. Massachusetts Boat Operations Restrictions ....................................6-24

Chapter Seven: Pulling It Together

The Marina Environmental Management Plan

7.1 Benefits of a Marina Environmental Management Plan ......................7-1

7.2 How to Develop a Plan ..................................................................7-2

Identify Pollution Sources and Select BMPs ............................................7-2

Prioritize BMPs ....................................................................................7-3

Identify BMPs to Implement Immediately ..............................................7-3

Identify BMPs for Future Implementation ..............................................7-4

Develop a Cost Strategy ........................................................................7-5

Develop a Schedule................................................................................7-5

Finalize Your Plan..................................................................................7-6

7.3 BMP Costs and Possible Funding Sources ........................................7-7

Appendices

Sample Contract from Edwards Boatyard ........................................................A-1Examples of Signs for the Marina ....................................................................B-1

Vendors of Marine Systems and Products ........................................................C-1

Massachusetts Pumpout List ..........................................................................D-1

Components of a Stormwater Pollution Prevention Plan....................................E-1

Index

Acknowledgements



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Chapter One: Introduction

1.1 The Case for Clean Marinas

1.2 The Guide and the Marina Assistance Program

1.3 Marina Regulations

1.4 Who Should Use this Guidebook

MarinasYacht Clubs

Boatyards

Municipalities

Boaters

Do-It-Yourselfers

1.5 Guide Purpose and Organization


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IntroductionMarinas, yacht clubs,and boatyards provide critical services to the boating public

maintaining,mooring, fueling,storing, and launching vessels of all kinds. While

modern facilities and efficient service are essential, clean water is a key attribute of

successful boating-based businesses, drawing boaters to the coast and keeping themcoming back year after year. The Massachusetts Clean Marina Guide is designed as a

reference for owners and operators of marine boating facilities,collectively referred

to throughout this document as marinas. It provides information on cost-effective

strategies and practices aimed at reducing marina and boating impacts on the coastal

environment.

This chapter is an introduction to the Clean Marina concept,as well as an overview

of how to use the Guide. It discusses the importance of protecting the environment,

explains how and why the Guide was developed, introduces regulatory require-

ments, explains how different groups can use this information,and presents the pur-pose and structure of the document.

1.1 The Case for Clean MarinasWhen marina operators adopt environmental practices and standards into their

daily operations and pass this ethic on to the boating public, their facilities pro-

tect coastal resources and thereby become Clean Marinas. Along with serving the

needs of their boating customers,Clean Marina staff members understand the poten-

tial environmental impacts of boating and willingly take responsibility to reduce

these impacts so people can use surrounding waters for other recreational activities,

such as swimming,fishing,and shellfishing.

A variety of routine activities can cause pollution. Boating,driving the car, fertilizing

the lawn, even walking the family dog can leave behind contaminants that are washed

into rivers, streams, lakes,and oceans when it rains. Nonpoint source pollution is the

technical term for this indirect runoff contamination. The combined impacts of

these countless small sources add up to significant pollution problems. In fact, with

the tremendous advances in reducing industrial discharges, improving sewage treat-

ment, and reducing other pointsources of pollution,nonpoint source pollution is

now the number one pollution problem facing coastal waters.

Marinas, like most other businesses, can generate significant amounts of nonpoint

source pollution through a variety of activities, including hull repair, engine mainte-

nance, and fueling.For example,paints, solvents, oil and gasoline,and other haz-

ardous materials generated through boat operation and maintenance are toxic to

humans and marine life.In addition,sewage released by boaters contains bacteria

Massachusetts Clean Marina Guide Introduction 1-1

Throughout this document, the

term marinas is used to refer col-

lectively to all facilities and individu-

als engaged in boat keeping,

storage, maintenance, and repairand includes boatyards, yacht clubs,

town docks and ramps, other marine

businesses, and do-it-yourselfers.

P l e a s e N o t e


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that can make people sick and contaminate shellfish resources.Finally, trash, which

can easily be blown off docks and boats and into the water, is unsightly and can be

harmful to marine animals that become entangled or swallow these materials.Be-

cause of the close proximity of marinas to the shore, the chance that these contami-

nants will reach the water is increased.

Adopting Clean Marina strategies and practices results in both environmental and

economic benefits.On the environmental side,reducing pollution improves water

quality around the marina, enhances marine habitats, and protects fish,shellfish,and

other marine life. Many economic opportunities are also available.For example,

boatyards using dustless vacuum sanders have found cost savings by virtually elimi-

nating cleanup time to collect dust from the ground and neighboring boats.Use of

oil absorption pads in boat bilges keeps oil drips from going overboard, thus avoid-

ing the expense of cleanup and fines. Selling greenproducts at the marina store

can also generate an important source of income.Most importantly, a Clean Marina

attracts and keeps customers,which is clearly good for business.

1.2 The Guide and the Marina Assistance ProgramDuring the last eight years, federal and state agencies have worked together to de-

velop strategies to reduce nonpoint source pollution from various land uses and ac-

tivities,including marinas.The Commonwealth of Massachusetts adopted these

strategies in The Massachusetts Coastal Nonpoint Pollution Control Plan. Rather

than create new laws, this plan is built on existing laws and regulations and focuses

on providing education and technical assistance. The Commonwealths Marina As-

sistance Program is a key component in this effort, providing information and techni-cal assistance to marina owners and operators on how to reduce nonpoint source

pollution impacts.

The Massachusetts Office of Coastal Zone Management (CZM) is taking the lead on the

Marina Assistance Program with support from the Office of Technical Assistance (OTA)

and other agencies within the Executive Office of Environmental Affairs (EOEA).

The Marina Assistance Program has three major components:

1.The Massachusetts Clean Marina Guide.

2. Workshops designed to help marina owners and operators understand and

implement pollution reduction practices.

3. On-going technical assistance.

The Massachusetts Clean Marina Guide forms the basis of the Marina Assistance

Program,serving as a reference manual of pollution prevention strategies for marina

owners and operators. The Guide was developed with the oversight and assistance

of a Marina Working Group, which includes numerous representatives from the ma-

rina industry (see below). This group was first convened to provide input during the

Massachusetts Clean Marina Guide Introduction1-2

According to the U.S. Environmen-

tal Protection Agency (EPA), the

single greatest pollution type con-

tributing to the overall degradation

of coastal and inland water quality

and aquatic habitat is nonpoint

source pollution. It's the main rea-

son that approximately 40 percent

of U.S. rivers, lakes, and estuariesare not clean enough to meet basic

uses, such as fishing or swimming.

See EPAs Office of Water website for

more on nonpoint source pollution:

www.epa.gov/owow/nps/whatis.html.

C o n s i d e r T h i s


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development of pollution control strategies in The Massachusetts Coastal Nonpoint

Pollution Control Plan. Working Group members have continued to assist CZM,

contributing valuable information, insight,and recommendations to this Guide.

CZM will hold workshops on Clean Marina management in the spring of 2001 to

present the Guide to marina owners and operators,as well as other interested indi-

viduals. In addition, both CZM and OTA will provide technical assistance through

the Marina Assistance Program. Specifically, CZM and OTA will be available to an-

swer questions about regulations that apply to marinas, provide environmental au-

dits to identify pollution control options, and assist with the development of a

marina pollution control plan.


The Massachusetts Office ofCoastal Zone Management (CZM)

is the state agency responsible for

developing and implementing

coastal policy to balance resource

use with resource protection along

the Bay States shoreline. For more

information, visit CZMs website at

www.state.ma.us/czm/ or call

(617) 626-1200.

Massachusetts Office of Technical

Assistance (OTA) is a non-regulatory

branch of the Executive Office of

Environmental Affairs (EOEA) that

helps manufacturers and industrial

facilities, municipalities, schools,

hospitals, households, and others

reduce or eliminate their use of tox-

ics and the generation of hazardous

byproducts. See www.state.ma.

us/ota/ for more information or call

(617) 626-1060.

For More I n fo

CZM would like to thank the following members of the Marina Working Groupwho were extremely helpful in developing this Guide.

George Bassett, Nantucket Boat Basin

Robert Buchsbaum, Massachusetts Audubon Society

Deirdre Buckley, Massachusetts Executive Office of Environmental Affairs (EOEA)

Toby Burr, Burr Brothers Boats, Inc.

Bruce Carlisle, Massachusetts Office of Coastal Zone Management (CZM)

Larry Chenier, Massachusetts Environmental Law Enforcement

Bill Clark, Metropolitan Area Planning Council (MAPC)

Peter Davidoff, Constitution Marina and Massachusetts Marine Trades Association

Anne Donovan, CZM

Cindy Dunn, Salem Sound 2000

David Fronzuto, Nantucket Marine & Coastal Resources Department and Cape & IslandsHarbormasters Association

Stephen George, Massachusetts Office of Technical Assistance (OTA)

Peter Heron, U.S.Coast Guard (USCG)

Buell Hollister, Massachusetts Division of Marine Fisheries (DMF)Brian Howley, USCG

Rob Hoyle, Manchester Marine

Steve Ivas, South River Initiative

Paul Keane, Massachusetts Boating and Yacht Club Association

Patti Kellogg, Massachusetts Watershed Initiative

Robin Lacey, CZM

Tom Leach, Town of Harwich and Saquatucket Municipal Marina

Steve McKenna, CZM

Tom McKenzie, Massachusetts Maritime Academy and Marina

Paul Milone, Massachusetts Harbormasters Association

Tim Moll, Brewers Plymouth MarineRebecca Monlteon, USCG

George Nice, Massachusetts State Fire Marshals Office

Ann Rodney, U.S. Environmental Protection Agency (EPA)

Ken Soltys, OTA

Charlie Swain, Edwards Boatyard and Cape Cod Marine Trades Association

Russ Vickers, Hawthorne Cove Marina and Salem Sound 2000

Tim Walter, Martin Walter Company

Nancy Wrenn, Massachusetts Department of Environmental Protection (DEP)


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1.3 Marina RegulationsAlthough Massachusetts Marina Assistance Program does not create any new regula-

tions, ensuring that your marina complies with existing laws is essential to reducing

environmental impacts and avoiding fines and other enforcement actions. This

Guide discusses federal and state laws and regulations that apply to marinas, but

does not cover local bylaws and ordinances. If you are unsure whether your city or

town has local bylaws regarding marina activities, contact your harbormaster, natural

resource department,or conservation commission.

Current state and federal laws regulate specific marina activities, such as hull mainte-

nance and pressure washing,fueling,and engine maintenance either through design

mandates or discharge restrictions for waste liquids.A number of laws govern the

handling and storage of hazardous materials, such as oil, paint, and solvents. Other

laws are triggered by a variety of construction activities that range from building a

shed to installing new docks and floats. These laws are listed in Chapter 6, which in-

clude sources for more information (phone numbers, website addresses, and regula-

tory citations).Feel free to call CZM for information and assistance.

1.4 Who Should Use the GuideThe primary audience for the Massachusetts Clean Marina Guide includes owners

and operators of marinas, yacht clubs, and boatyards. Other users may include mu-

nicipal officials (harbormasters,natural resource officers, etc.),boaters,and do-it-

yourselfers (people who maintain and store their own boats). Here is a summary of

how the Guide may apply to each of these groups.

> Marinas Many of the strategies discussed in this guide, including solid waste

management and stormwater management, apply to all marinas.Because each ma-

rina performs different activities and has different facilities and local environmental

conditions,the suite of management strategies selected will vary from one facility to

the next.

> Yacht Clubs While yacht clubs typically provide fewer services than marinas,

they can be very effective in promoting boat maintenance practices for do-it-your-

selfers, providing education to boaters, and setting up facilities for proper waste dis-

posal and recycling.

> Boatyards Because of the variety of chemicals that they use to repair and main-

tain boats (including paints,varnishes,epoxies,solvents,and oil),boatyards have the

potential to generate significant pollution.At a minimum, all boatyards should re-

view the status of their National Pollutant Discharge Elimination System (NPDES)



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Multi-Sector General Permit (MSGP) with the U.S.Environmental Protection

Agency and ensure that they are in compliance. The NPDES Program and its re-

quirements are discussed in Chapter 6. Other management strategies will also apply

depending on the services provided by each boatyard.

> Municipalities Municipal marinas, landings,and boat ramps provide the pub-

lic with a variety of services and facilities that can impact the marine environment.

Harbormasters play an important role in overseeing the activities at municipal facili-

ties, and in observing boater conduct on the water. This Guide will help harbormas-

ters and other municipal personnel promote sound environmental practices.

Municipal natural resource and conservation commission personnel should also re-

view the Guide to become knowledgeable about marina management practices that

protect the environment.

> Boaters The Boat Operation section in Chapter 4 addresses actions by

boaters that can harm the environment and the Boater Fact Sheets supplied at the

end of the Guide provide a variety of solutions. Marinas, harbormaster,and others

can use this information to establish boat operation procedures, as well as to edu-

cate the boating public.

> Do-It-Yourselfers Although do-it-yourselfers are not the prime audience for

this document,many of the management practices for hull scraping, engine mainte-

nance, boat cleaning,and other boat maintenance activities should be used by this

group.If you have do-it-yourselfers working at your facility, communicate this infor-

mation to them through fact sheets, signs,and other educational strategies.If they

show a lot of interest, suggest they call CZM at (617) 626-1212 for their own copy of

this Guide.



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1.5 Guide Purpose and OrganizationThe primary goal of the Massachusetts Clean Marina Guide is to help marina opera-

tors select appropriate pollution prevention strategies,called Best Management

Practices or BMPs.

The Guide is organized as follows:

Chapter 2 provides background on the potential environmental impact of marina

operations.

Chapter 3 discusses overall strategies and approaches to organize,run, and finance a

Clean Marina operation.

Chapter 4 provides Best Management Practices to reduce pollution for different ma-

rina activities,along with checklists to help you identify the most appropriate BMPs

for your facility.

Chapter 5 focuses on expanding or building marinas,giving details on how to meet

current regulations and design a Clean Marina from the beginning.

Chapter 6 summarizes the fundamental environmental regulatory programs that

apply to marinas.

Chapter 7 pulls all the other information together to develop a marina environmen-

tal plan to prioritize, finance, and schedule environmental improvements.


For good examples of marinas that

have adopted BMPs and how they

have benefited, order the free U.S.

Environmental Protection Agency

report Clean Marinas Clear Value,

Environmental and Business Success

Stories by calling (513) 891-6561and requesting a copy of publication

EPA 841-R-96-003. Or read and

download the report from the EPA

web site: www.epa.gov/owow/nps/

marinas/index.html.

For More I n fo

Best Management Practices (or BMPs) help solve the environmental pollution problems

that result from marina activities, such as boat cleaning, fueling, and waste disposal.

BMPs use one or more basic methods to control this pollution, such as preventing acci-

dental spills or leaks, capturing pollutants as they are produced, containing the spread of

spills or debris, reducing the use of a potentially harmful material, and filtering or trapping

out pollutants. They may include structural changes to a marina, acquisition and use of

environmentally-preferable products and equipment, and educational efforts aimed at

helping boaters understand how to prevent pollution. Additionally, you may develop your

own BMPs to address particular problems based on the specific conditions at your ma-

rina. Note that it is less costly to prevent pollution from occurring than to clean it up later.

Consider pollution prevention BMPs when prioritizing BMP implementation.

B M P s


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Chapter Two:The Coastal Environmentand Pollution Impacts

2.1 The Massachusetts CoastCurrents, Waves, and Tides

Coastal Water Chemistry

Coastal Habitats

2.2 Marina Activities and Potential Impactsto the Marine EnvironmentHull Maintenance

Boat Cleaning

Gas and Oil from Engine Maintenance, Bilge Water, and Fueling

Boat Sewage

Solid Waste

Fish Waste

2.3 Protecting the MassachusettsMarine Environment


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The Coastal Environmentand Pollution ImpactsNumerous plants and animals thrive in the water surrounding Massachusetts mari-

nas. Clean water is key to sustaining this diverse and abundant marine life.This

chapter provides an overview of the coastal environment around marinas, of marina

activities and the contaminants they can produce,and of the potential effects of those

contaminants on the marine environment.

2.1 The Massachusetts CoastThe Massachusetts coastline is unique and varied, to a large degree a product of gla-

cial activity that took place more than 10,000 years ago as well as shoreline processes

over time.In northern Massachusetts and Buzzards Bay, glaciers scoured the

bedrock to form rocky shores as seen at Cape Ann and Sconticut Neck.Interspersed

among the rocky stretches are sand and gravel deposits in the form of drumlins such

as the Boston Harbor Islands. Drumlins provide the anchor and sediment source for

barrier beaches, like those seen on Plum Island and on outer Cape Cod. Large rivers

like the Merrimack and the Taunton end as coastal estuaries where fresh and saltwa-

ter mix and nutrients contributed from the land feed the smallest marine organisms.

On the north coast, a large 10-foot tidal range results in a broad intertidal zone creat-

ing other diverse marine habitats.

Southeastern Massachusetts,Cape Cod, and the Islands represent part of the south-

ern margin of glacial activity. When the glaciers stopped their progression southward

and receded, they left behind deposits of sand and gravel that formed the Cape and

the Islands. The coastline is characterized by vast stretches of sandy beach and

bluffs. This shoreline has been sculpted by the Atlantic Ocean, which has eroded

some shores and built up others. Broad barrier beaches and associated dune systems

have formed along the outer coast, while extensive salt marsh systems have devel-

oped in protected bays behind these outer barriers.

Cape Cod also forms a major regional boundary between ecological zones,and sepa-

rates groups of marine organisms from north to south. For example,different species

of crustacean dominate north and south of Cape Cod. To the north, in what is re-

ferred to as the Boreal Region extending from Cape Cod to Newfoundland,Ameri-

can lobster and rock crab dominate. To the south, in the Mid-Atlantic Region,which

extends from Cape Cod south to Cape Hatteras North Carolina,blue crab domi-

nates. The migratory range of marine animals is also defined by these ecological

zones. For example,sea turtles, like loggerhead and green turtles, do not migrate fur-

ther north than Cape Cod.

Massachusetts Clean Marina Guide The Coastal Environment and Pollution Impacts 2-1


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Water temperature,more than any other factor, influences species distribution.Cur-

rents regulate the water temperature and thus determine these ecological zones.The

Mid-Atlantic Region is influenced by the Gulf Stream, which transports warm waters

from the lower latitudes northward to Cape Cod where it is deflected and directed

across the Atlantic to northern Europe. The Boreal region north of Cape Cod is in-

fluenced by the colder Labrador Current, which creates inshore currents south of

New Foundland across Nova Scotia and into the Gulf of Maine. As a result, theMassachusetts coastline has a rich assortment of marine habitats and species.

Currents, Waves, and Tides

Coastal energy in the form of currents,waves, and tides is fundamental to defining

coastal environments. Coastal energy sustains physical and chemical conditions of

each coastal habitat type,particularly by regulating salinity, temperature,and dis-

solved oxygen.

The Gulf Stream and the Labrador currents regulate regional water temperature.

Smaller, nearshore currents, further affect water movement along the coast and con-tribute to localized changes in water temperature, salinity, and species migration. In

addition,wave action influences the development of coastal habitats,both chemically

and physically. Chemically, waves mix the water column providing oxygen and nutri-

ents to organisms that live on the seabed. Mixing in the water column also provides

for moderated water temperature by transferring heat from surfaces waters warmed

by solar energy into the lower levels of the water column. Waves also help define the

physical nature of the coast by constantly altering the landscape.

Marine species have adapted to particular parts of the coast subject to different de-

grees of wave energy. Tides,on the other hand,have a buffering effect on coastalwater quality by flushing the coast twice daily and maintaining the strong ties be-

tween local waters and the ocean. This process also helps to moderate the effects of

pollution on coastal harbors by regularly exchanging coastal and ocean waters.Tides

also define distinct nearshore habitats between those that have adapted to regular ex-

posure to the sun and the wind and those that are protected by marine waters.

Marinas are often located in bays and coves that protect boats from the oceans wave

energy. Currents can be swift in these areas at mid-ebb or flood tide when the tides

are transferring water on and offshore. These conditions require that marina struc-

tures be designed and constructed to withstand energy produced by currents.

Coastal Water Chemistry

Important components of water chemistry in Massachusetts coastal waters include

salinity, temperature,dissolved oxygen, and nutrients.Ocean waters off the Massa-

chusetts coast have a salinity level of approximately 33 parts per thousand (ppt).

However,salinity varies greatly in nearshore waters where streams and rivers dilute

Massachusetts Clean Marina Guide The Coastal Environment and Pollution Impacts2-2


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the concentration of salt. Coastal water temperature is also variable.Surface waters

exposed to solar energy are warmed, while isolated bottom waters remain cooler.

Dissolved oxygen is also regulated by atmospheric conditions.Oxygen is rich at the

water surface where oxygen is regularly infused into the water, but is limited in bot-

tom waters that are not directly connected to sources of oxygen. Energy caused by

waves,currents, tides, wind,and other atmospheric conditions is an essential mecha-

nism for mixing oxygen into the bottom waters and sustaining the benthic life formsfound at depth.Nutrients,particularly nitrogen and phosphorus,stimulate growth of

the smallest marine organisms. Freshwater rivers and stream are important sources

of nutrients that contribute to an abundance of marine life.

The water in sheltered bays and estuaries where marinas are often located is less

saline, more nutrient enriched, and warmer. These conditions provide a good grow-

ing environment for plankton,which feed the fish nurseries of nearshore waters.

However, excess pollution from boat sewage systems,septic systems,and stormwater

runoff can upset the natural coastal water chemistry and lead to excessive algae

growth and depleted oxygen needed by marine life.

Coastal Habitats

Natural communities found along the coast include barrier beach/coastal dune,

rocky intertidal shore,salt marsh, eelgrass,mud flats, shellfish beds, the nearshore

seabed, and coastal ocean waters. These habitats have developed,as a result of local

physical and chemical conditions, and the marine organisms occupying each habitat

have adapted to these environmental conditions.Barrier beaches,for example,are

formed by wind and wave energy, and the marine organisms associated with barrier

beaches have adapted to and thrive on this high energy environment. Salt marsh, on

the other hand, is found in low energy environments where currents are weaker, and

sediments carried in the water are deposited.Colonization by salt marsh vegetation

helps stabilize these areas.Conversely, when salt marsh becomes exposed to waves, it

often sloughs and erodes.Other natural habitats are found in different nearshore

areas depending on the relationship of the daily tides. For example, eelgrass grows in

waters that are shallow at low tide where the plant is exposed to the suns energy

needed for photosynthesis. Mud flats are habitats that are covered by water at high

tide but are exposed to the atmospheric conditions at low tide.

Because coastal habitats of sheltered embayments are often found near marinas, con-

flicts between marina activities and these habitats can occur.While these fragile habi-

tats have adapted to their unique environments,each is sensitive to changes in water

chemistry, wave action, and boating activity, and thus, need to be safeguarded from

unintentional harm.


The land between low and high tide,

also known as the intertidal zone, isbiologically-productive, providing

habitat for many animals including

fish, shellfish, and shorebirds.


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2.2 Marina Activities and Potential Impacts to theMarine EnvironmentDeveloped areas, including marinas, yacht clubs, and boatyards, collect pollutants of

all types. While this Guide focuses on the strategies available to reducing pollution

from marinas to coastal waters, a basic knowledge of pollutants and their impacts on

the environment is helpful to understanding why pollution reduction is important.

Impacts from pollutants on marine life range from direct poisoning through inges-

tion of pollutants to indirect habitat degradation through pollution that produces

poor water quality and creates coastal waters uninhabitable by marine organisms.

Pollution often harms organisms by retarding or preventing reproductive develop-

ment. Indirect effects can also impact populations by reducing available habitat for

successful breeding. For example,where eelgrass beds are degraded by water pollu-

tion, scallops no longer have the habitat necessary for reproduction and early life

stage development.

The types of pollutants that are produced by individual facilities depend on the ac-tivities that occur there.Potential pollutants from marinas are described below by the

activities that generate them.

Hull Maintenance

Hull paints can contain metals,such as tin and copper, pesticides,and volatile or-

ganic compounds (VOCs),all of which are toxic to marine life. In addition,paints

and solvents release VOCs into the air,which are harmful to humans when inhaled.

Hull scraping and sanding generates paint chips that can be washed off-site during

rainfall events.Hull painting can expose fresh paint to marine organisms. Shellfishare particularly vulnerable to these pollutants because paint chips sink through the

water column and settle in the sediments where clams,oysters,and mussels live and

feed. The pollutants may be ingested and build up in the animal tissue without being

fatal to the specific individuals.However, when other animals consume the shellfish,

they can be affected. Over time, the pollutant works its way up the food chain impact-

ing both animals and humans.Long-term exposure to certain compounds can pro-

duce abnormal cell development and cancers.


Because they are located on the

water, all marinas have the postential

to impact the marine environment.


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Boat Cleaning

Soaps contain different cleaning agents,such as chlorine, ammonia,and phosphates,

at concentrations that can be harmful when ingested.Excess use of soaps and sol-

vents can harm marine life. The greatest impact occurs in surface waters,where

soaps are most concentrated and where plankton tiny creatures at the bottom of the

food chain is most abundant. Soaps can also break down oil products floating on

the water surface and become exposed to marine life that inhabits the water column.

Impacts decrease from the point of the spill as the concentration of soap is diluted.

Cleaning agent chemicals can also produce cumulative impacts. In particular, excess

nutrients, such as phosphates and nitrates,become available at lower concentrations

and accelerate the growth of plants. This can upset the natural balance in coastal

waters and lead to excessive plant growth and a decrease in dissolved oxygen.Use

of biodegradable products can significantly reduce problems associated with boat

cleaning. However, even biodegradable soaps can cause an adverse impact, and

should be used in moderation.

Gas and Oil from Engine Maintenance, Bilge Water, and Fueling

Oil and anti-freeze are polycyclic aromatic hydrocarbons, a family of chemicals that

can cause abnormal cell development and cancer.Oil also contains other chemicals

components,such as zinc and sulfur, at toxic levels. Solvents are comprised of car-

bon compounds that are also toxic.

Most petroleum products,particularly fuel and oil, will float if spilled on water. Bilge

water collects oil,grease,and other pollutants from the engine,leaky fuel lines,and

the washing down of the boat deck. When gasoline gets into the bilge,a hazardous

condition can develop that can lead to gas combustion and an explosion. Because

bilge water is always being collected, it and the pollutants it contains, are regularly


Volatile Organic Compounds (VOCs) are carbon-based chemical

compounds commonly used in paints, solvents, and thinners that

rapidly evaporate or volatize. In paints, the VOCs evaporate leaving

behind the dry pigment in the paint. The characteristics that make

VOCs effective for applying paints also make them a potentialair/water pollution hazard. When released into the atmosphere,

some VOCs can contribute to the development of ozone. (Ozone is

a primary ingredient in smog. It leads to health problem such as ag-

gravated asthma, reduced lung capacity, and increased susceptibility to disease.) VOCs

are also soluble in water, which can result in pollution. Furthermore, VOCs are flamma-

ble and can be toxic to humans and aquatic life. VOC-containing products can be re-

placed with less hazardous, aqueous or water-based substances at little or no extra cost.

V OC s

Read the product label. If the

cleaner is harmful to humans

when ingested, or when in con-

tact with eyes or skin, then it willharm marine life as well.

C o n s i d er T h i s


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discharged to coastal waters where the fuel or oil component can harm birds and

small animals, which also float or dive into the water. Floating oil also reduces the

normal oxygen exchange into the water.If a detergent is used to disperse the petro-

leum, it leaves the surface and mixes in the water column where it can harm the

plankton communities that are the basic food for fish and small marine animals.

Spills of gasoline and oil during boat fueling are a common source of marine pollu-

tion. While large spills are uncommon,small drip spills occur regularly, and can

cause minor impacts on the local marine environment.

Boat Sewage

Raw sewage contains water-borne disease and pathogens that can make people sick.

Boat holding tanks and marina rest rooms are potential sources of raw sewage. While

some marine toilets treat the waste prior to discharge,impacts from nutrient loading

and chemical additives still occur.Direct contact with pet waste can also bring peo-

ple in close contact with unhealthy bacteria. When it rains,pet waste runs into the

marina waters causing contamination. Waterbirds,such as geese, ducks,and gulls arealso major sources of waste contamination in the water as well as on docks and boats,

so feeding them should be discouraged. Bacteria from all these sources collect in

shellfish,and then can be passed on to humans who eat them.

Sewage and animal wastes contain nutrients, which, in large volumes, can disrupt the

natural chemical balance in water by reducing oxygen levels. Increased nutrients can

trigger a chain reaction that starts with the excessive growth of marine plants and

algae, and can lead to an overabundance of bacteria that breakdown dying plants and

at the same time further deplete dissolved oxygen in bottom waters. When oxygen is

depleted by the bacteria in bottom waters,a dead zone develops. This problem is ex-acerbated in protected coves and shallow waters, particularly during the very hot days

of summer often after heavy rains that add massive amounts of runoff from all sources.

Increased water temperature accelerates bacteria metabolism,activity, and growth.

Solid Waste

Just as with all human activities, marinas and boats produce waste.Trash and other

solid waste can be harmful to humans and wildlife. Some plastics,such as nylon fish-

ing line and plastic six-pack holders,can be ingested or entangle seabirds and fish.

Food garbage left uncovered can attract flies and gulls and can contribute to the nu-

trient overload in the water.


It requires only a small amount of

gasoline or oil to cover a large area

of water. For example, a single pint

of oil released onto the water can

cover one acre of water surface

area (Buller, 1995).



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In addition, large pieces of floating trash, such as boards, can be hazardous to boats

and can cause damage in collisions.Floating plastic bags can also be sucked into

cooling water intakes, resulting in overheating of engines,or can get wrapped around

propellers.Often, the most obvious problems with solid waste are aesthetic.Floating

paper cups and cigarette butts in the water are unsightly and detract from the beauty

of the ocean and from peoples enjoyment of their boating experience.

Fish Waste

If thrown into the water, dead fish and fish parts are unpleasant to look at and attract

gulls, which create their own mess to clean up.

The dumping of large quantities of fish wastes in the marina waters, for example,

during a fishing derby can harm marine life. Bacteria naturally colonize the waste and

break it down. Thus, large quantities of decomposing fish parts can deplete the oxy-

gen in confined water,especially during the hot days of summer when conditions are

best for bacteria production. This phenomenon can create low oxygen zones that

prevent marine life from surviving.

2.3 Protecting the MassachusettsMarine EnvironmentThe Massachusetts coastline includes natural features and aquatic life that are im-

portant to our heritage and our future. Pollution from many sources threatens to im-

pair these valuable resources.Marinas have a vested interest in protecting the coastal

waters because clean water sustains recreational boating and the marina industry.

The following chapters will help marina owners identify potential pollution prob-

lems at their facilities, plan for improvements, and implement best management prac-

tices to prevent pollution and protect Massachusettscoastal environment.



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Chapter Three:Clean Marina Operationsand Management

3.1 Staff Training

3.2 Tools to Help CommunicateClean Boating to CustomersCustomer Contracts

Contractor Agreements

Signs

Fact Sheets

Notices and Clean Boating Tips

Clean Boating Events

Promoting the Marinas Good Work

3.3 Financing Clean Business PracticesNew Services

Sell Environmentally-Preferable Products

Environmental Surcharge

Itemized Environmental Charges


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Clean Marina Operations& ManagementThe most efficient and effective way to run a Clean Marina is to incorporate envi-

ronmentally-sound approaches and management strategies into all aspects of marina

operation.The basic goal is to protect water quality and local marine habitats to cre-

ate a safe and healthy environment and to sustain a strong marine business. A well-

run Clean Marina encourages boaters to do their part to protect the environment.

This positive attitude is good for business,with boaters spreading the word that your

Clean Marina is a great place keep your boat.

This chapter focuses on ways to incorporate a Clean Marina philosophy into daily

marina operations.It begins with staff training,which is the key to enlisting your em-

ployees in environmental protection efforts.Then it discusses some of the many

ways to educate your customers about how to keep the coastal environment clean.

Finally, this chapter discusses strategies to make Clean Marina practices pay for

themselves through charging for new services,selling new products,and adding sur-

charges or itemized environmental charges for boaters.

This chapter discusses overall Clean Marina operations and management.See Chap-

ter 4 for Best Management Practices to reduce the environmental impacts of the spe-

cific activities that occur at your marina.

3.1 Staff TrainingMarina staff and dock crew can be effective spokespersons, providing boaters withvaluable information on how to protect the environment.Because they are the front-

line for communicating with customers, staff actions and attitude can greatly influ-

ence boater behavior at your marina.Consequently, it is essential that your staff is

prepared to provide customers with the right message, at the right time, in an appro-

priate manner. Routinely reinforce the following concepts with your staff so that they

are comfortable communicating environmental information to boaters:

Clean water is important to the marina business.

Pollution problems have solutions, so work with customers to achieve them.

Keeping a Clean Marina should be part of the daily work routine.

Be alert and prevent pollution, rather than cleaning it up afterward. Prevention is

both cheaper and more effective.

Massachusetts Clean Marina Guide Clean Marina Operations & Management 3-1

Check out other Massachusetts

marinas on the web at

www.charternet.com/marinas/

massachusetts.html.

For More I n fo


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Work with the boaters, rather than being confrontational.Building a positive work-

ing relationship and leading by example is more likely to persuade boaters to do

their share to keep the environment clean than lectures and reprimands.

Regularly scheduled training sessions will help your staff learn what to look out for at

the marina. Keep simple records of when you hold these training sessions,what was

covered, and who attended. Topics that should be covered include:

Spill response and proper handling of hazardous liquids, solvents, fuels, and

lubricants.

Trash and maintenance debris.

Boat sewage discharge.

Boat maintenance and cleaning activities.

Refer to the activities listed in Chapter 4 for more information on appropriate prac-

tices that you can share with your staff.

3.2 Tools to Help CommunicateClean Boating to CustomersA wide range of tools is available to communicate your Clean Marina message. The

most important tool, as discussed above, is staff-customer interaction.This regular

communication can be augmented by a mix of other tools, which are discussed below.

Customer Contracts

Most marinas have annual lease contracts for customers who rent dock or land space

and moorings. An effective way to educate boaters and to enlist their formal support

for protecting the environment is to clearly state the marinas environmental rules in

the marina contract.Some marinas call this a clean boating pledge,an environmental

contract,or a best management practice agreement. Specifically, the customer con-

tract could require boaters to:

Conduct all vessel maintenance activities in designated locations and use dust- free

tools when appropriate.

Use appropriate spill prevention and collection measures during all maintenanceactivities, including oil changes.

Use environmentally-preferable green cleaning products, such as biodegradable

soaps, whenever possible.

Use oil absorbent pads in bilges at all times and install fuel/air separators in the fuel

tank vent line.

Massachusetts Clean Marina Guide Clean Marina Operations & Management3-2

Training programs that cover a

broad range of issues for marina

staff and boaters are available

from the following organiza-

tions: Massachusetts Maritime

Academy (508) 830-5098 and

the International Marina Institute

(941) 480-1212.

Training


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Dispose of trash in appropriate containers or take it home.

Recycle all products that the marina accepts.

Use a pumpout facility as frequently as needed.

Clean up after pets.

Use the fish cleaning station or clean fish and dispose of waste offshore, not in themarina waters or dumpster.

A sample of an environmental contract from Edwards Boatyard is provided as Appen-

dix A. Call Charlie Swain at (508) 548-2216 for more information.

Contractor Agreements

Establishing agreements with outside contractors before they do work at the marina

is a commonly accepted practice.These agreements should include provisions re-

quiring contractors to meet the marinas environmental policies and procedures.

Such agreements should require contractors to:

Abide by all Best Management Practices used by the marina under its National

Pollutant Discharge Elimination System (NPDES) permit.

Be responsible for removal and disposal of all wastes.

Keep work areas clean to prevent the spread of pollution.

Use precautionary measures to prevent the escape of hazardous materials. (Specific

measures will depend on the contractors activity, however,general principles such

as isolating the work area and confining the activity would be appropriate.)

Use environmentally-preferable alternatives. (These requirements will again depend

on the contractor. Refer to the specific activity in Chapter 4 for lists of products.)

Sign in at the marina office before beginning work on any boat and sign out when

the job is done.

Signs

Interpretive and instructional signs placed at marinas and boat-launching sites are a

key method of providing information to the boating public. Signs should educate

customers in a positive way as to what activities are allowed and where they shouldbe conducted. A sign listing the environmental services provided by the marina

should also be available. Ideas for different types of language for signs are provided

in Appendix B.


R E C Y C L E

U S E D O I L

H E R E


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Fact Sheets

Handing out fact sheets is a cost-effective way to inform customers about environ-

mental protection efforts.Sample fact sheets are provided on the inside back pocket

of this guide covering the following topics:

Boat Maintenance (including Boat Cleaning and Hull and Engine Maintenance)

Managing Wastewater (Bilgewater,Sewage,and Graywater)

Trash, Garbage,and Hazardous Waste Disposal Tips

Boat Operation and Fueling

Non-Toxic Cleaning Alternatives

Feel free to copy these fact sheets and distribute them to your customers.Free fact

sheets on nonpoint source pollution can also be downloaded from the U.S.Environ-

mental Protection Agencys Office of Water website at www.epa.gov/owow/nps/facts/.

Notices and Clean Boating Tips in Mailings

To continue to inform your customers about water quality protection, include an en-

vironmental note or tip in each regular invoice mailing or newsletter. If possible, have

the tip correspond to seasonal activities and issues. For example,spring tips could

cover proper collection and recycling of shrink wrap, marina requirements for boat

scraping and painting,and the benefits of placing oil absorption pads into the bilge

before launching.Summer tips could include a list of pumpout facilities and hours of

operation (call CZM at (617) 626-1212 for the current list),a list of materials ac-

cepted for recycling at the marina, and information on proper boat cleaning tech-

niques. Fall tips could include information on bilge cleaning and the use of

environmentally-preferable antifreeze. Finally, winter tips could cover replacing out-

of-date toilets,installing fuel/air separators in the vent line,adding a holding tank, re-

placing old hoses that became permeable to sewage gas,or ordering engine tune ups

for more fuel efficiency.

Clean Boating Events

Including Clean Marina information and activities as part of already organized

events is a great way to get the message to boaters. Examples of special events suit-

able for clean boating activities include fishing derbies,boat shows,cruises,picnics,

regattas,and sailing races.Some good how to activities include demonstrations on

the use of: oil absorption pads to keep bilges and water clean, greenproducts for

boat cleaning, and spill-free fueling techniques for boats and personal watercraft.

Specific activities are also a valuable way to communicate clean boating practices.

For example, you could invite a local school science teacher to visit and temporarily

set up an aquarium as a showcase of the plant and animal life being protected.You

could also conduct a contest with a prize for the customer that guesses the number of


Join the free National Clean

Boating Campaign and become

a partner marina by handing outtheir free fact sheets and organ-

izing some of the activities suc-

cessfully used by other marinas.

Visit their web site at www.

cleanboating.org and download

their materials.

C lea n B oa t in g


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species found living in the marina. In addition,you can organize a cleanup day for

the shore around the marina, and/or hold a cleanup cruise to an island or other lo-

cation popular with boaters.Invite scuba divers to do a marina bottom cleanup and

retrieval of lost objects.

Promoting the Marinas Good Work

Spread the word about your efforts to protect the environment whenever possible.Community members, particularly boaters looking for a marina,will be interested in

what you are doing. The following strategies can help you promote your efforts:

Participate in association groups (such as the Massachusetts and Cape Cod Marine

Trades Associations) and promote your efforts through the industry. Check out

websites for the Massachusetts Marine Trade Associations at http://boatmassachu-

setts.com/ and the Cape Cod Marine Trades Association at www.cc-waterweb.com/

ccmta/index.htm.

Send a press release to your local paper and/or trade-related publications about the

improvements the marina has undertaken,or about the success of a particular pro-

gram, like pumpout operations.

Regularly communicate with the harbormaster, Conservation Commission, and Se-

lectmen about marina activities and invite them to participate in clean boating events.

3.3 Financing Clean Business PracticesOne of the keys to successfully implementing Clean Marina strategies is to help

boaters understand the relationship between good environmental quality and theirrecreational experience.When a clean marina program is operating properly, boaters

will not only be willing to participate in keeping coastal waters clean, they will be will-

ing to invest their time and money. The facility owner can help make Clean Marina

practices pay for themselves by marketing new services,renting equipment, selling

environmentally-preferable products, and/or implementing an environmental surcharge.

New Services

Adding environmental services can create new revenue streams for your marina. For

example,you can charge a fee to perform environmental audits to identify practices,

repairs,or products that can reduce a vessels impact on the environment. Such anaudit could include engine inspections for clean, leak-free,and efficient operation;

Marine Sanitation Devices (MSD) system inspections for compliance with Federal

law and no discharge area use; fuel system inspections including tanks and lines; and

bilge inspections for possible oil leaks. Audits can also indirectly generate business

by recommending greenproducts or services sold at the marina, or by recom-

mending the installation of pollution-prevention devices.


COASTSWEEP is the state-wide

beach cleanup organized by CZM.

Every year the cleanups are led by

a dedicated group of local volun-

teer coordinators who in 2000

organized about 4,000 volun-

teers who collected almost

70,000 pounds of trash and

marine debris from over 150

locations. Some marinas sponsor

cleanups including Edwards Boat-

yard in Falmouth. For more infor-

mation on how your marina can

participate call (617) 626-1223.

B ea ch C lea n u p


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The marina can also charge for regular maintenance services, including dripless oil

changes,engine cleaning and repair, and bilge cleaning and repairs to oil leaks. If

your marina is equipped to service boats,some services that you may be able to add

to your repair shop include hull vacuum sanding, water-based bottom painting,

air/fuel separator installation, holding tank replacement and Y-valve removal, and

through hull plugging.

The marina could also rent or sell equipment to do-it-yourselfers. Examples of

equipment that you could rent include dustless vacuum sanders and sandpaper

disks, tarps or filter cloth for use beneath boat during work,and spray booths.

Sell Environmentally-Preferable Products

Selling environmentally-preferable products at the marina will help your customers

practice clean boating, while at the same time financially supporting your environ-

mental efforts. The following products (many which are listed in Chapter 4) could

be sold at the marina store:

glycol antifreeze

environmentally-preferable teak cleaner

absorbent pads

biodegradable soaps

low nitrogen detergents

non-toxic,water-based paints

holding tank additives

Environmental Surcharge

Some facilities have included an environmental surcharge to help cover the costs of

future environmental improvements,such as stormwater management and pumpout

systems.Keep customers informed and show them formal progress on improvement

activities to help solidify their support for and understanding of the surcharge.

Itemized Environmental Charges

Requiring payment for tangible items can help cover costs for keeping the marina

clean and efficient. This approach may help to avoid complaints about blanketcharges.For example,specific charges could be used to cover disposal costs for used

oil, oil-saturated absorbent pads, other hazardous wastes, shrink-wrap,and solid

waste. In rare cases, charging for the proper disposal of materials may encourage ille-

gal actions for those looking to avoid the charge.To avoid this illegal dumping, con-

sider an environmental surcharge instead.

While this chapter focues on overall approaches to operating and managing a Clean

Marina, see Chapter 4 for details on the Best Management Practices to use to address

specific issues at your marina.


Brewer Yacht Yards adds a 1% envi-

ronmental surcharge on all invoices

to cover the often hidden Clean

Marina costs, such as landscaping,

staff training, environmental permit

applications, and use of general

clean up products and disposal. They

report that few of their customers

object and most appreciate the visi-

ble efforts the marinas have made

toward cleaner operations.

Fu n d in g T ip


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Chapter Four: Activities andEnvironmental Practices

4.1 Hull Maintenance and Cleaning

4.2 Boat Cleaning

4.3 Engine Maintenance

4.4 Bilge Water Handling

4.5 Fueling

4.6 Spill Response

4.7 Boat Sewage and Wastewater Management

4.8 Shoreside Facilities andPet Waste Management

4.9 Solid Waste Management4.10 Hazardous Materials and

Hazardous Waste Management

4.11 Fish Waste Management

4.12 Stormwater Management

4.13 Boat Operations


29/167

Activities andEnvironmental PracticesAll marinas are different and can have different activities going on that change from sea-

son to season.As a result,every marina will use different pollution reduction strategies.

Marinas are required under federal and Massachusetts laws and regulations to take

actions to control pollution from normal operations and to prevent accidents. Some

regulations, such as the National Pollutant Discharge Elimination System (NPDES),

require that you take specific actions.Other laws, particularly the Coastal Zone Act

Reauthorization Amendments of 1990, leave it up to the regulated party (e.g. marina

owners) to decide which practices to implement. This chapter lists a range of proven

options.Dont feel you are limited to this list. If you have a better way to control a po-

tential pollutant,use it. Because marina operators, by the nature of their business, are

creative problem solvers, CZM encourages innovative solutions to be developed and

used.

This chapter is organized according to the following activities that occur at marinas:

Hull Maintenance and Cleaning

Boat Cleaning

Engine Maintenance

Bilge Water Handling

Fueling

Spill Response

Boat Sewage and Wastewater Management

Shoreside Facilities and Pet Waste Management

Solid Waste Management

Hazardous Materials and Hazardous Waste Management

Fish Waste Management

Stormwater Management

Boat Operations

For each activity, a list of applicable state and federal laws that apply is provided. The

laws are followed by a list of Best Management Practices (BMPs), or pollution pre-

vention strategies and technologies, which will reduce the environmental impact of

each activity. Some BMPs will help you achieve compliance with existing laws and

you should be sure that you are implementing these BMPs first. Other BMPs are

provided as suggestions for achieving pollution prevention goals.

Massachusetts Clean Marina Guide Activities and Environmental Practices 4-1

Best Management Practices (BMPs)help solve the environmental pollu-

tion problems that result from marina

activities, such as boat cleaning, fuel-

ing, and waste disposal. BMPs use

one or more basic methods to control

this pollution, such as preventing

accidental spills or leaks, capturing

pollutants as they are produced,

containing the spread of spills or de-

bris, reducing the use of a potentially

harmful material, and filtering or trap-

ping out pollutants. They may includestructural changes to a marina, acqui-

sition and use of environmentally-

preferable products and equipment,

and educational efforts aimed at

helping boaters understand how to

prevent pollution. Additionally, you

may develop your own BMPs to

address particular problems based

on the specific conditions at your

marina. Note that it is almost

always less costly to prevent pollu-

tion from occurring than it is to

clean it up later. Consider pollution

prevention BMPs when prioritizing

BMP implementation.

BMPs

While each marina business is

unique, all facilities can adopt envi-

ronmental practices.


30/167

The following symbols are provided to help you identify which BMPs will help you

comply with existing laws and which are recommended for protecting marina waters.

> BMP will assist with Regulatory Compliance

> BMP recommended

Read about each activity that applies to your facility, and follow these steps.

1. Review the regulations for each activity and make sure your facility is in compli-

ance.Refer to Chapter 6 for more details on applicable regulatory programs and

contact the agency personnel for details.

2. Read the list of BMPs and highlight those that might work at your marina.

3. Complete the checklist at the end of the section to conduct a formal inventory of

pollution sources and available BMPs.

4. Make a list of immediate tasks in the Actioncolumn on each checklist, such as

names and numbers of marinas to call, vendor contact information,and sources of

regulatory requirements that need follow-up.

Once you have completed all of the checklists, you have the basic information for a

marina environmental plan. Chapter 7 will help you refine your plan including prior-

itizing,financing, and scheduling environmental improvements.

Massachusetts Clean Marina Guide Activities and Environmental Practices4-2

Consider making multiple copies of

the activity checklists for future use.

Then you can use these checklists

in conducting annual self-audits, to

document progress and evaluate fu-

ture improvements.



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4.1 Hull Maintenanceand Cleaning

If not properly controlled, hull maintenance activities, including scraping,

sanding, pressure washing, and painting, can put toxic pollutants into the marine envi-

ronment. Where marinas do not provide these services, Do-It-Yourselfers and outside

contractors may be performing this work on the marina's property. In all cases, this

section provides you with tools to reduce the potential negative impacts from hull

maintenance.

Best Management PracticesHull Scraping, Sanding, and Washing

Hull scraping, sanding, and washing releases pollutants that are bound up in hull

paint and exposes marine organisms to those pollutants. Employing the following

BMPs will minimize the potential for pollutants associated with hull paint to

reach coastal waters.

Designated Maintenance Areas: Restrict all major vessel repair and maintenance work

to designated work areas that are located away from the bulkhead. Activities that

should be restricted to designated areas include abrasive blasting, pressure washing,hull scraping and sanding, and hull painting. Maintenance work such as painting,

scraping, and hull cleaning should be done on land, not at marina slips or moorings.

Underwater cleaning of hulls must be prohibited. The area should be provided with

containment as outlined below.

Containment: Maintenance areas should be designed and equipped to minimize the

spread of pollutants by:

G Containing all waste and wastewater generated from hull maintenance activitiesfor proper treatment and disposal; and


Marinas that provide commercial

boat maintenance services where

maintenance activities are exposed

to stormwater are likely to require

a National Pollutant Discharge

Elimination System (NPDES)

Multi-Sector General Permit from

the US Environmental Protection

Agency (EPA). See Chapter 6 for a

description of the program and the

requirements for complying orcall the EPA NPDES Program at

(617) 918-1615.

Please Note

Boat bottoms should be

maintained in desingated

areas away from the water.

LEGAL REQUIREMENTS

The following laws apply to hull maintenance activities. If you perform or allow hull

maintenance services and activities at your facility, please read the summary of these

regulatory programs in Chapter 6.G National Pollutant Discharge Elimination System (NPDES) Multi-Sector

General Permit (MSGP) for Industrial Activities

G Organotin Anti-Foulant Law

G Massachusetts Air Quality Program

G Massachusetts Hazardous Waste Regulations

G Massachusetts Industrial Wastewater Regulations

G Massachusetts Waterways Regulations


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G Covering the containment areas to prevent rainwater from entering these areas.

If covering the containment areas is not feasible, then all the stormwater collected

within the containment areas must be handled as industrial wastewater generated from

hull maintenance activities. Berms or curbs made of concrete or asphalt can be used to

enclose the area and prevent runoff from entering or leaving the maintenance area. To

prevent pollutants from seeping into the soil below, all maintenance areas should be lo-

cated on top of a hard, impermeable surface, such as blacktop. These maintenance

areas must be kept clean or covered to prevent rainwater from entering these contain-

ment areas and washing away the remnant pollution left over after work, or alterna-

tively, the work area must drain to a storage tank for further recycling, treatment or

disposal.

Pressure Washwater Management: Pressure washwater is considered to be a process

wastewater (or industrial wastewater). Therefore, discharge of pressure washwater to

coastal waters, the ground, or a sewer system is illegal without a permit. To meet per-

mit conditions, significant pretreatment of the wastewater prior to discharge would

likely be requiredregardless of the discharge option chosen. In addition, most

pretreatment systems (for discharge) must be operated by staff properly certified

by the state.

The significant investments in permitting, training, and operator certification for

discharge systems likely make them cost prohibitive. Therefore, recycling systems that

treat the wastewater for reuse as washwater without discharge may be a more viable

option. The recycling systems without discharge need no operational permit if there

is no hazardous waste involved. However, these systems will require periodic mainte-

nance. No matter the disposal option selected, all pressure wash facilities must develop

a system to collect the wastewater for treatment, recycling, or offsite disposal. For

smaller yards that wash fewer boats, collecting all washwater for offsite disposal may

be the most cost effective option.

The following practices should be considered when addressing pressure washing at

marinas.

Collect Pressure Washwater: Pressure washwater must be collected for pretreatment

prior to reuse, permitted discharge, or disposal. Vessels must be washed over an imper-

vious pad that can collect all wastewater (process wastewater).

Handle Pressure Wastewater Properly: One of the following options must be selected

for the management of wastewater from pressure washing operations. Facilities will

need to consider many variables before selecting an appropriate management option.

The number of boats washed (wastewater volume), site characteristics, sewer availabil-

ity, staff technical ability, cost, and other factors must all be weighed before one of the

following options is selected:

G Recycle washwater for reuse. No discharge permit is needed, but this may require

periodic hauling for disposal of residual wastewater and solids.

Massachusetts Clean Marina Guide Activities and Environmental Practices4-4

Paint chips that are collected

must be tested and confirmed as

non-hazardous before disposal

as solid waste. See Section 4.10

for more information on Haz-

ardous Waste Management.

Hazard Alert

EPA regulates the discharge of

pressure washwater under the

NPDES Permit Program. If you

discharge any washwater to

marine (or other surface) waters,

you are required to obtain a

NPDES Individual Permit for

Industrial Discharges. This waste-

water is not covered by the

NPDES Multi-Sector General

Permit for stormwater

management.

Please Note

HULLMAINTENANCE


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G Haul wastewater to treatment facility. This activity will need an industrial

wastewater holding tank compliance certification (DEP01) submitted to the

Massachusetts Department of Environmental Protection (MassDEP).

G Discharge to sewer system. This activity may require a permit from the local sewer

authority, sewage treatment plant, or MassDEP. In addition, a MassDEP certified

operator may be required to run the treatment system.

G Discharge to surface waters. This activity will require a NPDES permit from EPA

and MassDEP. In addition, a MassDEP certified operator may be required to run

the treatment system.

G Discharge/Infiltrate to ground. This activity requires a groundwater discharge permit

from MassDEP and a MassDEP certified operator may be required to run the

treatment system.

Work Indoors: Where practical, conduct vessel maintenance indoors or under

temporarily covered areas where the rain cannot cause runoff. Sheet plastic shelters are

widely used by many marinas.

Work Away from the Water: At a minimum, always move each boat inland to the

approved work area before scraping or power washing the hull. Do not allow anyone

to perform hull maintenance activities on the launch ramp area or in the lift well.

No In-Water Bottom Cleaning: Removal of seaweed and other marine growth on

the bottom of boat hulls by divers must be prohibited. This practice is sometimescarried out by owners of sail boats before races in regattas to enhance boat speed.

Cleaning of seaweed also removes anti-foulant paint and associated pollutants.

Dustless Vacuum Sanders: Dustless sanders use industrial vacuum cleaners to trap

dust created in the sanding process before it becomes airborne. As the sander removes

paint, dust is drawn into several holes located through the sanding pad. The dust is

then sucked into a vacuum container that can be emptied for disposal. Dustless vac-

uum sanders are one of the best ways to control paint dust before it can become a pol-

lutant. Added advantages include keeping a clean workplace, reducing health risks to


Parkers Boatyard in Cataumet, MA uses vacuum sanders because they are cost effec-

tive, cleaner, and more efficient than old sanding methods. Parker does not allow peo-

ple to do their own bottom work at the boatyard for both environmental and economic

reasons. Other yards, such as Manchester Marine, encourages Do-It-Yourselfers. They

rent sanders to their customers, which has allowed Manchester Marine to pay off the

cost of the sanders and make a small profit. Call Parker's Boatyard at (508) 563-9366

or Manchester Marine at (978) 526-7911 to find out how vacuum sanders have worked

at their marinas.

LOCAL EXAMPLE

A dust free sander reduces un-

healthy dust by as much as 98

percent, which makes for a health-

ier work area and cleaner natural

environment. The dust free

sanders are cost efficient as well.

A report written by Martin Walter

Co., Inc indicated that a marina

manager in Missouri increased

productivity by cutting sanding

time by 30 percent, decreasing

cleanup labor by 80 percent, and

providing rental profit through

weekend rentals to customers.]

Consider This


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workers, and reducing clean-up costs and time. If you choose dustless sanders as a

BMP, require all staff, outside vendors, and Do-It-Yourselfers to always use this equip-

ment. Train staff to use equipment and develop a user manual for Do-It-Yourselfers.

See Appendix C for vendors of dustless sanders.

Tarps and Filter Cloth: Use tarps and/or filter cloth to catch scrapings and other de-

bris produced during maintenance work. Tarps and cloth are inexpensive low-tech

methods to collect debris before it can be washed into coastal waters by stormwater.

Filter cloths are better than tarps when boat work is expected to last longer than one

day. Should it rain, the water passes through the cloth instead of washing the debris

off the tarp. Have these items available to rent or sell to customers who do their own

boat maintenance.

Clean Up Designated Areas: Clean up the designated work area after scraping and

painting. Leaving areas cluttered and messy will cause spills and allow pollutants to be

tracked outside the work area.

Painting

Because hull paints contain toxic pollutants, they should be used with care. Consider

the following BMPs when painting your boat.

Designated Maintenance Areas: Restrict mixing of paints, solvents, and reducers, as

well as the painting itself, to designated areas that are located on a hard surface and iso-

lated from the weather.

Prohibit Spray Painting on the Water: Sprayed paint can be difficult to control.

Paint can be inadvertently sprayed into the water and expose marine life to toxicchemicals.

Clean Up Paint and Supplies: Treat paint spills like oil spills. Clean up immediately

with absorbent materials, paper, and/or rags. Since liquid paints are classified as haz-

ardous material, dispose of paint brushes and paint properly (see Section 4.10). If your

customers are permitted to paint their own boats, require them to clean up after them-

selves. Provide paint disposal areas for customers to use. Before disposal, all paint cans

and worn out brushes and rollers should be allowed to air dry.

Appropriate Use and Storage of Hazardous Materials and Waste: Make certai

Documents

Massachusetts Clean Marina Guide